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Effective Date: August 11, 2026
Last Updated: August 11, 2026

Qubera Holdings LLC ("Qubera," "Company," "we," "us," or "our") respects the privacy of consumers and recognizes the importance of protecting personal information entrusted to us.

This Privacy Policy describes how Qubera may collect, receive, use, disclose, maintain, and protect personal information in connection with our website, debt settlement administration and servicing activities, consumer support operations, creditor negotiations, settlement administration, payment-related activities, technology systems, and related services.

Qubera Holdings LLC
505 Carr Road, Suite 200
Wilmington, DE 19809

Website: quberahc.com
Email: help@quberahc.com
Phone: (916) 530-7346

1. SCOPE OF THIS PRIVACY POLICY

This Privacy Policy applies to personal information Qubera receives or processes through quberahc.com and in connection with services performed by Qubera.

Qubera provides debt settlement administration and servicing functions. Depending upon the applicable program and contractual relationship, Qubera's activities may include administration of enrolled debt settlement accounts, creditor negotiations, payment and settlement coordination, compliance oversight, consumer support, settlement execution, account servicing, and program performance management.

In some circumstances, Qubera may receive personal information directly from consumers. In other circumstances, Qubera may receive information from debt settlement providers, program partners, creditors, debt collectors, financial institutions, payment providers, or other authorized sources.

2. INFORMATION WE MAY COLLECT

The information Qubera collects or receives depends upon your relationship with Qubera and the services being provided.

A. Personal Identifiers

We may collect or receive:

• name;

• mailing address;

• email address;

• telephone number;

• date of birth;

• customer or account identifiers;

• electronic signatures; and

• other identifying or contact information reasonably necessary to provide services.

B. Financial and Account Information

In connection with debt settlement administration, we may receive or process information concerning:

• creditors;

• creditor account information;

• debt balances;

• debt types;

• account numbers or partial account numbers;

• payment history;

• settlement balances;

• settlement offers;

• dedicated account information;

• scheduled deposits;

• settlement payments;

• income and expense information;

• financial hardship information; and

• other financial information reasonably necessary to administer or service a debt settlement program.

C. Debt and Creditor Information

We may process information concerning:

• enrolled debts;

• creditors;

• debt collectors;

• debt buyers;

• collection accounts;

• creditor correspondence;

• collection activity;

• settlement negotiations;

• settlement offers;

• settlement agreements;

• settlement authorizations;

• payment arrangements; and

• account status.

D. Communications and Customer Service Information

We may collect and maintain communications involving Qubera, including:

• telephone communications;

• customer service interactions;

• emails;

• text messages;

• electronic messages;

• documents;

• correspondence;

• consumer requests;

• complaints;

• settlement authorizations; and

• other communications relating to services.

Calls may be monitored or recorded for quality assurance, training, security, documentation, or compliance purposes where permitted by applicable law and subject to any notice or consent requirements imposed by applicable law.

E. Website, Device, and Technical Information

When you interact with quberahc.com or Qubera's electronic systems, we may automatically collect certain technical information, including:

• IP address;

• browser type;

• device type;

• operating system;

• pages viewed;

• referring URLs;

• dates and times of access;

• session information;

• cookie identifiers;

• security information; and

• similar technical or usage information.

3. SOURCES OF PERSONAL INFORMATION

Depending upon the circumstances, Qubera may obtain personal information from:

• consumers;

• debt settlement providers;

• authorized program partners;

• creditors;

• debt collectors;

• debt buyers;

• financial institutions;

• dedicated account providers;

• payment processors;

• customer service providers;

• technology providers;

• consumer-authorized representatives;

• professional service providers;

• publicly available sources; and

• other sources permitted by applicable law.

The information available to Qubera depends upon the services Qubera performs in connection with a particular consumer or account.

4. HOW WE USE PERSONAL INFORMATION

Qubera may use personal information to:

• establish and administer consumer accounts;

• service debt settlement programs;

• communicate with consumers;

• verify consumer and account information;

• review enrolled debts;

• maintain creditor account information;

• communicate with creditors and debt collectors;

• negotiate potential settlements where authorized;

• receive and evaluate settlement offers;

• present settlement opportunities to consumers;

• obtain and document settlement authorizations;

• coordinate settlement payments;

• administer settlement agreements;

• process or facilitate authorized transactions;

• monitor dedicated account information where authorized;

• provide customer service and account support;

• monitor program performance;

• maintain records;

• investigate and respond to complaints;

• prevent fraud and unauthorized activity;

• authenticate users;

• protect consumers and Qubera's systems;

• conduct quality assurance and training;

• conduct compliance monitoring;

• satisfy contractual obligations;

• satisfy legal and regulatory requirements;

• respond to lawful legal process;

• enforce applicable agreements;

• improve our operations, services, systems, and technology; and

• otherwise perform services authorized by consumers or our contractual partners.

5. HOW WE MAY DISCLOSE PERSONAL INFORMATION

Qubera may disclose personal information when reasonably necessary to provide, administer, support, or protect services.

Depending upon the applicable program, recipients may include:

• creditors;

• debt collectors;

• debt buyers;

• creditor representatives;

• law firms;

• debt settlement providers;

• program partners;

• dedicated account providers;

• banks and other financial institutions;

• payment processors;

• technology providers;

• communications providers;

• customer service providers;

• document providers;

• compliance providers;

• auditors;

• accountants;

• attorneys and professional advisers;

• regulators;

• government authorities; and

• other service providers performing authorized functions.

Qubera may also disclose information when required or permitted by law, including in response to subpoenas, court orders, regulatory requests, governmental inquiries, or other lawful process.

6. SALE AND SHARING OF PERSONAL INFORMATION

Qubera does not sell consumer personal information for monetary consideration as part of its ordinary debt settlement administration and servicing activities.

Qubera may disclose personal information to service providers, creditors, debt collectors, financial institutions, contractual partners, and other authorized parties when reasonably necessary to administer accounts, negotiate or execute settlements, process authorized transactions, provide customer support, maintain systems, conduct compliance activities, or otherwise provide authorized services.

Certain state privacy laws may define terms such as "sale," "sharing," or "targeted advertising" more broadly than an ordinary exchange of personal information for money.

Where applicable law provides consumers with a right to opt out of qualifying sales, sharing, targeted advertising, or profiling, Qubera will process legally valid requests as required by applicable law.

7. SENSITIVE PERSONAL INFORMATION

Because of the nature of debt settlement administration, Qubera may receive or process information considered sensitive under applicable privacy laws.

Sensitive information may include certain financial information, account information, authentication information, or other information classified as sensitive under applicable law.

Qubera uses sensitive information only for purposes reasonably necessary and permitted to:

• provide and administer services;

• maintain consumer accounts;

• perform authorized settlement activity;

• process or coordinate authorized transactions;

• authenticate users;

• prevent fraud;

• maintain security;

• satisfy legal and regulatory obligations; and

• perform legitimate operational and compliance functions.

8. PAYMENT AND FINANCIAL INFORMATION

Certain payment or financial transactions may be processed by independent financial institutions, dedicated account providers, or payment processors.

Qubera may receive information concerning transactions when reasonably necessary to administer a consumer's debt settlement program.

Qubera does not represent that it directly holds consumer funds merely because Qubera has access to information concerning a consumer's dedicated account or settlement transactions.

9. COOKIES AND TRACKING TECHNOLOGIES

Qubera's website may use cookies and similar technologies to:

• provide website functionality;

• maintain security;

• authenticate sessions;

• remember preferences;

• understand website usage;

• diagnose technical problems; and

• improve website performance.

Some cookies may be necessary for website functionality.

Where required by applicable law, users may be provided with mechanisms to manage certain cookie or tracking preferences.

10. INFORMATION SECURITY

Qubera uses administrative, technical, and physical safeguards designed to protect personal information against unauthorized access, acquisition, disclosure, alteration, misuse, loss, or destruction.

Depending upon the systems and information involved, these safeguards may include:

• access controls;

• authentication procedures;

• encryption;

• security monitoring;

• role-based access;

• employee and contractor access restrictions;

• vendor controls;

• security procedures;

• incident response procedures; and

• other safeguards appropriate to the sensitivity of the information involved.

No electronic system, network, transmission method, or storage system can be guaranteed to be completely secure.

Accordingly, Qubera cannot guarantee absolute security of information.

11. DATA RETENTION

Qubera retains personal information for as long as reasonably necessary to:

• provide and administer services;

• maintain consumer accounts;

• maintain transaction and settlement records;

• satisfy contractual requirements;

• comply with applicable laws and regulations;

• satisfy recordkeeping requirements;

• investigate and resolve complaints;

• prevent fraud;

• resolve disputes;

• enforce agreements; and

• establish, exercise, or defend legal claims.

Retention periods may vary depending upon the type of information, the consumer's relationship with Qubera, applicable contracts, and applicable legal or regulatory requirements.

12. CONSUMER PRIVACY RIGHTS

Depending upon your state of residence and applicable law, you may have certain rights concerning your personal information.

These rights may include the right to:

• confirm whether Qubera processes your personal information;

• request access to certain personal information;

• request correction of inaccurate personal information;

• request deletion of certain personal information;

• obtain a portable copy of certain personal information;

• obtain information concerning categories of information collected or disclosed;

• opt out of certain qualifying sales of personal information;

• opt out of certain sharing or targeted advertising;

• opt out of certain profiling where applicable;

• limit certain uses or disclosures of sensitive personal information where applicable; and

• appeal certain decisions Qubera makes regarding a privacy request.

These rights are subject to applicable exemptions, exceptions, verification requirements, record-retention requirements, and other legal limitations.

Qubera will not unlawfully discriminate against a consumer because the consumer exercised a privacy right protected by applicable law.

13. HOW TO SUBMIT A PRIVACY REQUEST

Consumers may submit questions or requests concerning their personal information using the following contact information:

Email: help@quberahc.com
Phone: (916) 530-7346

Written requests may also be directed to:

Qubera Holdings LLC
505 Carr Road, Suite 200
Wilmington, DE 19809

When submitting a request, please provide sufficient information for Qubera to identify the request and, where applicable, verify your identity.

Qubera may request additional information reasonably necessary to verify that the person submitting a request is the consumer to whom the personal information relates.

Authorized agents may submit requests where permitted by applicable law, subject to applicable verification and authorization requirements.

14. CALIFORNIA RESIDENTS

California residents may have additional rights under applicable California privacy laws.

Depending upon Qubera's applicability thresholds, the nature of the information involved, and applicable exemptions, these rights may include rights concerning:

• access;

• disclosure;

• correction;

• deletion;

• portability;

• certain sales or sharing of personal information;

• certain uses of sensitive personal information; and

• non-discrimination for exercising legally protected privacy rights.

California consumers may submit privacy requests using:

Email: help@quberahc.com
Phone: (916) 530-7346

Certain information or processing activities may be exempt from particular California privacy requirements because the information is subject to another federal or state privacy regime or another statutory exemption applies.

15. PRIVACY RIGHTS IN OTHER STATES

Residents of Delaware and other states may have additional privacy rights under applicable state privacy laws.

Because Qubera provides or supports services nationwide, applicable rights may differ based upon a consumer's state of residence, the nature of Qubera's relationship with the consumer, applicable statutory thresholds, and available legal exemptions.

Qubera will process qualifying privacy requests in accordance with applicable law.

Privacy requests may be submitted to help@quberahc.com or by calling (916) 530-7346.

16. CHILDREN'S PRIVACY

Qubera's debt settlement administration and servicing activities are not directed to children.

Qubera does not knowingly offer debt settlement administration services to individuals under 18 years of age.

If Qubera learns that personal information from a child has been collected in circumstances where such collection is prohibited, Qubera will take reasonable steps to address the information as required by applicable law.

17. THIRD-PARTY WEBSITES AND SERVICES

Qubera's website or systems may contain links to or integrate with independent third-party websites, platforms, or services.

Those third parties may maintain their own privacy policies and practices.

Qubera is not responsible for the independent privacy or security practices of unaffiliated third parties.

Consumers should review the privacy policies of third-party services with which they interact.

18. BUSINESS TRANSFERS

If Qubera is involved in a merger, acquisition, financing, restructuring, reorganization, sale of assets, change of control, bankruptcy, or similar business transaction, personal information may be disclosed or transferred in connection with that transaction, subject to applicable legal requirements.

19. LEGAL, REGULATORY, AND SECURITY DISCLOSURES

Qubera may preserve, use, or disclose personal information when reasonably necessary to:

• comply with applicable federal, state, or local law;

• comply with regulatory requirements;

• respond to lawful governmental requests;

• respond to subpoenas, court orders, warrants, or other legal process;

• investigate suspected fraud or misconduct;

• investigate security incidents;

• protect consumers;

• protect Qubera's rights, systems, personnel, or property;

• enforce contractual rights; or

• protect the security and integrity of Qubera's operations.

20. CHANGES TO THIS PRIVACY POLICY

Qubera may update this Privacy Policy periodically to reflect changes in our services, technology, vendors, business practices, data practices, or applicable laws.

The revised Privacy Policy will contain an updated "Last Updated" date.

Where legally required, Qubera will provide additional notice concerning material changes.

Consumers are encouraged to review the Privacy Policy periodically.

21. CONTACT US

If you have questions, concerns, complaints, or requests concerning this Privacy Policy, your personal information, or Qubera's privacy practices, please contact:

Qubera Holdings LLC
505 Carr Road, Suite 200
Wilmington, DE 19809

Website: quberahc.com
Email: help@quberahc.com
Phone: (916) 530-7346

Consumers seeking to exercise applicable privacy rights may submit requests using the contact information above.

We may take reasonable steps to verify your identity before fulfilling certain requests, as permitted or required by applicable law.

INTERIM POLICY NOTICE

This Privacy Policy is an interim policy intended for use while Qubera Holdings LLC develops and reviews its final privacy and compliance documentation with qualified legal and regulatory counsel.

The final policy should be reviewed against Qubera's actual data collection practices, vendors, technology systems, consumer agreements, state licensing footprint, payment processes, information-sharing relationships, and applicable federal and state privacy requirements.